On October 28, 2022, Canada announced additional sanctions related to Russia, targeting thirty-five senior officials of already sanctioned energy entities, including those of Gazprom and its subsidiaries, as well as six entities in the energy sector. These parties are believed to be “involved in Russia’s ongoing violations of Ukraine’s sovereignty and territorial integrity” and are the latest persons designated under Schedule 1 of the Special Economic Measures (Russia) Regulations (the “Regulations”). Prime Minister Trudeau has also indicated an intention to sanction members of the Russian justice and security sectors.
Generally speaking, designation under Schedule 1 of the Regulations imposes an asset freeze and dealings prohibition against the designated person. Subject to limited exceptions, any person in Canada or any Canadian outside Canada cannot:
- deal in any property, wherever situated, that is owned, held or controlled by or on behalf of a designated person whose name is listed in Schedule 1;
- enter into or facilitate, directly or indirectly, any transaction related to such a dealing;
- provide any financial or other related services in respect of such a dealing;
- make available any goods, wherever situated, to a designated person listed in Schedule 1 or to a person acting on their behalf; or
- provide any financial or related service to, or for the benefit of, a designated person listed in Schedule 1.
Due to ongoing developments in the region, Canada may announce and implement further measures in alignment with its allies.
An unofficial copy of the legislative amendments to the Special Economic Measures (Russia) Regulations that came into effect on October 28, 2022 are available on Global Affairs Canada’s website at here.